SCOTUS Rules Unanimously In Favor of Special Education Student
The justices ruled 9-0 in favor of Miguel Luna Perez Tuesday in a case that presented a kind of Catch-22 related to special education claims. The ruling, penned by Justice Neil Gorsuch, isn't one likely to garner a ton of headlines — but is one that promises to be meaningful to families of children with special educational needs.
Some background on the dispute:
Miguel Perez is a deaf student whose Michigan public school district denied him a qualified sign language interpreter for 12 years. His family raised claims on his behalf under two laws: 1) the Individuals with Disabilities Education Act (IDEA); and 2) the Americans with Disabilities Act (ADA). The IDEA (the same statute that focuses on federal guidelines for implementing Individualized Education Plans) does not allow a claimant to recover monetary damages — but the ADA does.
Perez's lawyers settled the IDEA claim, but not the ADA claim. However, the federal courts refused to even hear his ADA claim for money damages on the grounds that Perez "failed to exhaust his administrative remedies." The "exhaustion" requirement is a standard one for administrative proceedings, but in this case, it created something of a legal conundrum given that Perez couldn't have litigated his ADA damages claim together with his IDEA claim.
The Supreme Court unanimously ruled in Perez's favor, holding that the ADA claim may indeed have been viable — a serious blow for a school district that is accused of habitually failing to meet the needs of a disabled student.
Justice Gorsuch penned a relatively short opinion in which he recounted some of the ways the Perez family alleged that the Sturgis Public School District came up short:
It assigned aides who were unqualified, including one who attempted to teach herself sign language.
It allowed aides to be absent from the classroom for hours on end.
It misrepresented Perez's educational progress, gave him inflated grades, and advanced him from grade to grade without regard for his progress.
It allowed the family to believe Perez was on track to graduate from high school, only to learn months before graduation that Perez would not be awarded a diploma.
The Court's decision now means that the Perez family will have the chance to litigate those contentions — or perhaps more likely, to force a settlement with their district.
Gorsuch's legal analysis was based primarily on canons of statutory interpretation, none of which turned on concepts specific to special education or disability law. Still, the fact that the justices sided unanimously with Perez is important, particularly in the context of special education rights.
Though the Supreme Court has often sought to minimize clutter on the federal docket, it opted to revive Perez's money-damages lawsuit. By dispensing with the requirement of a procedural hurdle, the justices handed families like the Perezes a powerful weapon to be wielded against non-compliant school districts: the threat of money damages.
School districts, like all bureaucracies, are often motivated into action by the threat of costly litigation. Accordingly, one family's case over a sign interpreter in Michigan has potential to improve the services offered to children with other needs across the country.
You can read the full ruling in LUNA PEREZ v. STURGIS PUBLIC SCHOOLS here.